Rain Files OCC Trust Bank Application: Not Approved, No Deposits

Stablecoin payments platform Rain filed an application with the OCC on Oct 5, 2026 to set up Rain National Trust Bank in New York. It is a filing, not an approval: nothing has been approved yet.

If approved, the proposed uninsured national trust bank would hold digital assets and U.S. dollars in custody, manage reserves for permitted stablecoin issuers under the GENIUS Act, and issue and redeem dollar-backed stablecoins for institutional clients. Rain says it would not take deposits, offer consumer accounts, make commercial loans, or carry FDIC insurance. Rain itself would stay a payments platform, with the trust bank as a separately capitalized subsidiary. The filing comes three days after the Independent Community Bankers of America sued the OCC over crypto national trust charters, arguing the agency went beyond its authority. The OCC review includes a public comment period, and no decision date has been given.

In this OnlyFintechs episode we walk through what was filed and what is still pending:

• Exactly what Rain filed, and why "filed" is not "approved"
• What a national trust bank can and cannot do: custody and trust powers, no deposits, no loans
• How the filing fits the GENIUS Act path for uninsured national banks as stablecoin issuers
• Where Rain sits in the OCC's recent trust-charter wave, from Circle to Bastion, Agora and Catena
• Why bank trade groups, including ICBA, are fighting the charter model in court

Keywords: Rain, Rain National Trust Bank, OCC, national trust bank, trust charter, stablecoin, GENIUS Act, custody, reserve management, Brandon Soto, Farooq Malik, ICBA, Bank Policy Institute, fintech charter.

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